U.S. Supreme Court

Miranda violation doesn’t give rise to civil claim for damages, SCOTUS rules

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The U.S. Supreme Court ruled 6-3 Thursday that a certified nursing assistant who made an incriminating statement during an interrogation can’t sue the sheriff’s deputy who questioned him without a Miranda warning.

The high court said Terence Tekoh could not sue for an alleged violation of his Fifth Amendment right against compelled self-incrimination under Section 1983 of the federal civil rights statute.

A Miranda violation does not constitute a violation of the Fifth Amendment right against self-incrimination, the Supreme Court majority said in an opinion by Justice Samuel Alito. Instead, Miranda protections constitute a set of “prophylactic rules” designed to prevent constitutional violations, he said.

“Those rules, to be sure, are ‘constitutionally based,’” Alito wrote, “but they are prophylactic rules nonetheless.”

The sheriff’s deputy had questioned Tekoh at his job in Los Angeles after a female patient accused him of sexual assault. Tekoh gave a statement apologizing for inappropriately touching the patient’s genitals.

The statement was used against Tekoh at his California trial on a charge of unlawful sexual penetration after a judge ruled that the statement could be admitted because Tekoh was not in custody when it was made. Tekoh was acquitted.

Alito said there was no justification to expand Miranda to confer a right to sue under Section 1983.

“If a Miranda violation were tantamount to a violation of the Fifth Amendment, our answer would of course be different,” Alito said.

Justice Elena Kagan dissented, joined by Justices Stephen Breyer and Sonia Sotomayor.

The case is Vega v. Tekoh.

The American Civil Liberties Union had represented Ernesto Arturo Miranda in the case that led to the 1966 decision in Miranda v. Arizona, the group noted in a press release.

Brett Max Kaufman, senior staff attorney with the ACLU, said in the press release Miranda warnings have been “part of the fabric of law enforcement interactions with the public for more than 60 years.”

By denying the right to sue under Section 1983 for a Miranda violation, “the court further widens the gap between the guarantees found in the Constitution and the Bill of Rights and the people’s ability to hold government officials accountable for violating them,” Kaufman said.

Hat tip to SCOTUSblog, which had early coverage of the decision.

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